August 31, 2026
PALTmed has signed on to a coalition letter, led by LeadingAge and joined by 19 organizations from across the Medicare continuum, urging the Centers for Medicare & Medicaid Services (CMS) to reconsider the provider enrollment provisions in the CY 2027 Home Health Prospective Payment System proposed rule (CMS-1844-P). The letter was submitted on August 31.
Although these provisions sit inside a home health payment rule, they would apply to every provider and supplier enrolled in Medicare, including PALTmed members. That placement is a central concern, as enrollment changes tucked into a home health rule leave many affected providers unaware that their Medicare participation is at stake.
The coalition supports strong action against fraud, waste, and abuse. The problem is how these provisions are drawn. As proposed, they would sharply expand CMS' authority to deny, revoke, and bar enrollment while removing the standards and safeguards that protect legitimate providers. The result: severe enrollment consequences triggered by clerical errors, conduct outside a provider's control, or broadly defined third-party associations rather than actual misconduct. When a legitimate provider is pushed out of Medicare, beneficiaries lose access to care.
The letter makes four core recommendations:
Use standalone rulemaking. CMS should move the enrollment changes into a separate proposed rule, consistent with more than two decades of practice.
Separate intentional misconduct from good-faith error. A clerical mistake should not carry the same consequences as deliberate fraud. CMS should adopt materiality and intent standards before denial or revocation.
Set due diligence protections for third-party relationships. The rule sweeps a far broader universe of employee and affiliate management into the basis for revocation. There should be a meaningful connection between a third party's conduct and the provider, as well as a good-faith safe harbor.
Preserve due process and an opportunity to cure. Providers should be able to correct errors, cure deficiencies, and rebut CMS' claims before losing enrollment.
PALTmed will continue to track the rule as it moves toward a final version.